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The evidence before us discloses no reason for the original
abatement of $867.92. On the contrary, the evidence justifies
imposition of the late filing additions.
Petitioner also contends that respondent conducted an
unauthorized second examination of his books in violation of
section 7605(b). Petitioner’s error arises from his misreading
of the certificate of assessment and payments. This document
indicates that the matter of petitioner’s 1995 tax liabilities
was transferred without assessment from the IRS Examination
Division to the IRS Appeals Office and then, when petitioner’s
administrative appeal was unavailing, back to the Examination
Division for the assessment of the taxes in issue. It does not
show that there was an unauthorized second examination of
petitioner’s books and records with respect to his 1995 taxable
year.
Our review of the procedures used in assessing and
collecting petitioner’s Federal income tax liabilities supports
the Appeals officer’s determination that the Notice of Federal
Tax Lien should not be withdrawn. Petitioner has not shown that
respondent erred in declining to invalidate assessments of
Federal income taxes for 1995 or 1997. The assessments were made
within the applicable period of limitations and were valid.
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